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The ITAT held that the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
The ITAT held that the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
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